Ezel / IRS Rulings / 200913018

CCA 200913018: Section 6230(c) allowed two years to issue the refund

Number
200913018
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Special Rules with Respect to Credits or Refunds
Topics
Procedure, penalties, and administration
Code sections
§ 6230
Ruling dated
July 1, 2008
Publicly released
March 27, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel approved an approach concerning a partnership-related refund. The writer clarified that section 6230(c) provided two years to issue the refund, rather than one year. The brief, redacted release does not describe the underlying refund or the proposed approach.

Ruling snapshot

  • Question: Was the period for issuing the refund one year or two years?
  • Outcome: Advice given: section 6230(c) provided a two-year period.
  • Key authorities: IRC § 6230(c).

Full text (IRS public release)

ID: CCA-711010-08 Number: 200913018
Release Date: 3/27/2009
Office: --------------
UILC: 6230.04-00

From: -------------------
Sent: Tue 7/1/2008 10:10 AM
To: --------------------
Cc: -------------------------------------------------------------------------------------------------------------------
Subject: RE:

That works. You would actually have two years under section 6230(c) to issue a refund rather than one
year.

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